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Abstract

Land tenure refers to "the manner in which a person held or owned real property." The land tenure system in a country governs the traditional or legal rights that individuals or groups have in land and the resulting social relationships among the people. Land tenure systems exist in different forms. In countries where private land ownership is allowed and the rule of law is followed, private property rights are protected by law and cannot be violated by the government or individuals. To carry out development for public purposes, the government can, however, compulsorily take land from private owners by means of acquisition or resumption according to the provisions of the law. This article studies and compares the features of the compensation principles for compulsory acquisition of leasehold land in Hong Kong and Australia to determine which of them offers more favorable compensation to dispossessed landowners. It focuses on the compensation principles for the market value of the land taken.